The document describes the One National Program established in 2009 to harmonize federal and state fuel economy and greenhouse gas regulations for cars and light trucks. The initial standards for 2012-2016 aimed to reach an average of 35.5 mpg by 2016. Additional standards for 2017-2025 finalized in 2012 require reaching 54.5 mpg by 2025 through continued technology improvements. The standards apply footprint-based targets to account for vehicle size and provide flexibilities to facilitate compliance.
3. OneNationalProgram101
Fuel Economy and Greenhouse Gas Regulators
Department of
Transportation
Regulates Fuel Economy
through the Corporate
Average Fuel Economy (CAFE)
Program
State of California
Has its own Greenhouse
Gas (GHG) Standards
Environmental
Protection Agency
Regulates Greenhouse
Gas (GHG) Emissions
3
4. OneNationalProgram101
In 1975, Congress passed the Energy Policy and Conservation Act (EPCA). This law requires
the Department of Transportation’s (DOT) National Highway Traffic Safety Administration
(NHTSA) to issue corporate average fuel economy standards (referred to as “CAFE”
standards) for passenger cars and light trucks manufactured in each model year. EPCA
requires that CAFE standards must be set at the “maximum feasible” level of vehicle fuel
efficiency.
Separate standards are set for the car and light duty truck categories. Each standard is set
on a fleet-average basis so manufacturers can produce a range of vehicle sizes and types to
meet consumer demand. The fuel economy performance of vehicles is determined by
laboratory tests conducted under EPA procedures, in conjunction with that agency’s air
pollutant emissions tests. The law includes a variety of credits to provide manufacturers
flexibility in meeting standards and to incentivize various new technologies.
In 2007, as part of the Energy Independence and Security Act (EISA), Congress changed the
way the CAFE program sets fuel economy standards. Instead of a fleet average, DOT now
sets attribute-based CAFE standards for each manufacturer based on vehicle footprint.
Federal Fuel Economy Standards (CAFE)
4
5. OneNationalProgram101
On April 2, 2007, the U.S. Supreme Court in the Massachusetts v. EPA case ruled
that EPA has the authority under the Clean Air Act to regulate greenhouse gas
(GHG) emissions from motor vehicles. The Court held that carbon dioxide and other
GHGs are “pollutants” under the Clean Air Act and can be regulated by EPA if EPA
determines that they “endanger” public health and welfare.
While the Court recognized the overlap between EPA regulating vehicle GHG
emissions and NHTSA issuing CAFE standards, it stated that “there is no reason to
think the two agencies cannot both administer their obligations and yet avoid
inconsistency.”
On December 7, 2009, EPA responded to the Supreme Court’s ruling by making an
“endangerment” finding and began the process of developing regulations to
establish light vehicle GHG emissions standards.
Federal Motor Vehicle Greenhouse Gas (GHG) Standards
5
6. OneNationalProgram101
A special provision in the Clean Air Act allows the state of California to adopt its own
emissions standards. Among other requirements, EPA must agree that California’s
standards are in aggregate at least as protective of public health and welfare as
federal standards, and then grant the state a waiver. Other states may not adopt
their own standards generally, but may (under specified conditions) adopt standards
that are identical to the California standards.
In 2004, California issued its own GHG regulations which required fleet-wide
reductions in emissions of CO2 and other GHG emissions from motor vehicles
beginning with the MY2009 and ending in MY2016.
EPA granted a waiver of Clean Air Act preemption to California for its motor vehicle
GHG program. There are 13 states and jurisdictions that adopted the California
GHG standards. Because these standards are based on fleet-wide average
emissions for each state, automobile manufacturers have to adjust the types of
vehicle models sold in each state to meet the GHG reduction targets required.
California GHG Standards
6
8. OneNationalProgram101
On May 19, 2009, President Obama announced a National Program to increase the
fuel economy and reduce greenhouse gas (GHG) emissions from passenger cars and
light trucks.
The “One National Program” was designed to harmonize differing government-
mandated vehicle standards having closely related purposes, including the average
fuel economy standards issued by the DOT’s National Highway Traffic Safety
Administration (NHTSA) and GHG emissions standards issued by EPA, the State of
California, and other states that have adopted variations of California’s standards.
These separate standards remain in place, but are harmonized and coordinated
under the One National Program to create a single set of obligations for vehicle
manufacturers.
8
One National Program: Phase 1, MY2012-2016
9. OneNationalProgram101
On September 24, 2009, the California Air Resources Board (CARB) adopted GHG
emissions standards for new cars and trucks that are sold in that state in MY2009-
2016.
On February 25, 2010, California announced its commitment to allow vehicles that
both meet the National Program standards and are sold in that state to be deemed
in compliance with its standards for MY2012-2016.
In April 2010, EPA and NHTSA announced the adoption of the first phase of the One
National Program, including harmonized federal GHG emissions and fuel economy
standards for MY2012-2016 cars and light duty trucks, raising the fleet average fuel
economy to 35.5 miles per gallon (mpg) by MY2016.
9
One National Program: Phase 2, MY2017-2025
10. OneNationalProgram101
On May 21, 2010, President Obama directed the federal agencies to extend the One
National Program to MY2017-2025 cars and light duty trucks.
On January 27, 2012, the California Air Resources Board unanimously approved a
package of new emissions rules for cars and light duty trucks through MY2025.
On August 28, 2012, the Obama Administration issued the final MY2017-2025
Greenhouse Gas and CAFE standards, increasing the fleet average of 35.5 mpg by
MY2016 to 54.5 mpg by MY2025. A mid-term review and related rulemaking is
required by the agencies to assess the feasibility of these standards and, if
necessary, increase or decrease these standards.
One National Program
10
11. OneNationalProgram101
What are the Benefits of Having a Single National Program to Regulate
both Fuel Economy and Greenhouse Gas Emissions?
It allows automobile manufacturers to build a single light-duty national
fleet that satisfies all requirements under both federal programs and the
standards of the State of California (and other states that have adopted the
California standards).
Allowing the production of a single fleet of vehicles avoids unnecessary
economic and administrative burdens that would result from the
enforcement of differing regulations throughout the country.
The One National Program provides critical nationwide environmental and
energy benefits while ensuring that consumers have a full range of vehicle
choices and avoiding unnecessary burdens.
Q
A
11
12. OneNationalProgram101
What is the Relationship Between Fuel Economy and Greenhouse Gases?
Fuel economy is the
relationship between the
distance traveled by an
automobile and the amount
of fuel consumed over that distance. When fuel is consumed, carbon
dioxide is produced as a byproduct.
GHGs are gases in the atmosphere that absorb and emit radiation within
the thermal infrared range. The primary naturally occurring GHGs in the
Earth’s atmosphere are carbon dioxide, methane, nitrous oxide, water
vapor and ozone. Certain synthetic industrial chemicals, such as air
conditioning refrigerants, are also GHGs.
Q
A
12
g/gal
g/km x 1.6 km/m
MPG
13. OneNationalProgram101
CONTINUED:
What is the Relationship Between Fuel Economy and Greenhouse
Gases?
Carbon dioxide (“CO2”) is the principal GHG gas emitted by gasoline
powered motor vehicles. The amount of CO2 emissions from a vehicle
relates directly to the amount of carbon-containing fuel consumed by
the vehicle. Unlike conventional air pollutants, such as hydrocarbons
and oxides of nitrogen, CO2 emissions cannot be reduced by capturing
them or chemically altering them with pollution control devices.
Since the first voluntary fuel economy labeling program in 1973, motor
vehicle fuel economy has been determined by measuring the amount of
CO2 and other carbon-containing compounds emitted from the vehicle’s
tailpipe and using a basic calculation to determine how much fuel was
burned to create those emissions.
Q
A
13
14. OneNationalProgram101
CONTINUED:
What is the Relationship Between Fuel Economy and Greenhouse
Gases?
Fuel economy continues to be measured by EPA based on CO2
emissions, and then converted by simple arithmetic into miles-per-gallon
fuel economy reports for the general public.
By definition, therefore, regulating CO2 emissions is the same thing as
regulating fuel economy. As NHTSA has explained, “a tailpipe carbon
dioxide regulation and a fuel economy regulation are essentially
equivalent: they each in effect regulate fuel economy.”
Q
A
14
15. OneNationalProgram101
What National Program Standards Were Initially Adopted?
The standards initially adopted were for MY2012-2016. They gradually
increase in stringency to levels equivalent to 250 grams per miles GHG
emissions and 35.5 miles per gallon (mpg) in fuel economy, for MY2016, on
an average industry fleet wide basis (including cars, light and medium
trucks, minivans, vans, and SUVs).
Q
A
15
16. OneNationalProgram101
CONTINUED:
What National Program Standards Are in Place Today?
Projected Fleet-Wide Emissions Compliance Levels under the CO2
Standards (g/mi) and Corresponding Fuel Economy (mpg)
Q
A
Vehicle Type 2012 2013 2014 2015 2016
Passenger Cars (g/mi) 263 256 247 236 225
Light Trucks (g/mi) 346 337 326 312 298
Combined Cars & Trucks (g/mi) 295 286 276 263 250
Passenger Cars (mpg) 33.8 34.7 36.0 37.7 39.5
Light Trucks (mpg) 25.7 26.4 27.3 28.5 29.8
Combined Cars & Trucks (mpg) 30.1 31.1 32.2 33.8 35.5
Source: EPA April 2010 Fact Sheet on 2012-16 Standards, http://www.epa.gov/otaq/climate/regulations/420f10014.pdf.
16
17. OneNationalProgram101
What Additional Standards Were Set?
In August 2012, final rules governing the second phase of the National
Standards, covering MY2017-2025 cars and trucks, were issued.
Like the MY2012-2016 standards, these requirements will apply to all
cars, light and trucks, minivans, vans, and SUVs. The standards are
projected to achieve by 2025 a fleet average of 163 grams per miles GHG
emissions, which is equivalent to 54.5 miles per gallon (mpg).
Q
A
17
18. OneNationalProgram101
CONTINUED:
What Additional Standards Were Set?
To achieve the 54.5 mpg goal in MY2025, cars’ emissions must improve by five
(5) percent per year on average from MY2017-2025, and trucks must improve
by an average of three-and-a-half (3.5) percent between MY2017-2021 and an
average of 5 percent between MY2022-2025.
Q
A
Projected Fleet-Wide Emissions Compliance Targets under the Footprint-Based
CO2 Standards (g/mi) and Corresponding Fuel Economy (mpg)
Vehicle Type 2016
Base
2017 2018 2019 2020 2021 2022 2023 2024 2025
Passenger Cars (g/mi) 225 212 202 191 182 172 164 157 150 143
Light Trucks (g/mi) 298 295 285 277 269 249 237 225 214 203
Combined Cars & Trucks
(g/mi)
250 243 232 222 213 199 190 180 171 163
Combined Cars & Trucks
(mpg)
35.5 36.6 38.3 40.0 41.7 44.7 46.8 49.4 52.0 54.5
Source: EPA Regulatory Announcement, August 2012, http://www.epa.gov/oms/climate/documents/420f12051.pdf
18
19. OneNationalProgram101
How will vehicles change as a result of the new standards?
EPA and NHTSA project that a variety of technological changes will be
implemented by vehicle manufacturers in order to comply with the
National Program standards.
Q
A
Improvements in the efficiency
of gasoline engines and in
transmissions
Vehicle weight reduction
Lower tire rolling resistance
Improvements in vehicle
aerodynamics
Diesel engines
More efficient vehicle
accessories
Vehicle air conditioners will
continue to improve by
becoming more efficient
The increased electrification of
the fleet through the expanded
production of
stop/start, hybrid, plug-in
hybrid electric and electric
vehicles
19
20. OneNationalProgram101
CONTINUED:
How will vehicles change as a result of the new standards?
The agencies project that the new technologies will add, on
average, about $2,800 to the cost of new vehicles by 2025.
However, the agencies project that this increased cost will be offset by
lifetime fuel savings of new 2025 vehicles of $5,700 to $7,400.
Q
A
20
21. OneNationalProgram101
What Form do the National Standards Take?
Separate standards are established to require improved vehicle fuel
economy (NHTSA-CAFE standards) and reduced GHG emissions (EPA-GHG
standards).
While the One National Program has a goal of achieving 54.5 mpg in
MY2025, each vehicle model has its own individualized fuel economy and
GHG targets based on a vehicle size criterion, called the “footprint.” In
general, the smaller the vehicle’s footprint, the more stringent the
standard the vehicle must meet. Each manufacturer’s has a unique
standard that is calculated by averaging the sales-weighted footprint
targets of all of its vehicles.
Q
A
21
22. OneNationalProgram101
CONTINUED:
What Form do the National Standards Take?
Separate emissions standards were also created for the GHGs nitrous
oxide and methane.
The One National Program also includes a variety of credits and flexibility
mechanisms. Some of the credits are designed to encourage
manufacturers to implement specific advanced technologies. Other
mechanisms provide compliance flexibility to manufacturers, while
maintaining the overall energy and emissions benefits of the program.
Q
A
22
23. OneNationalProgram101
How Were the MY2017-2025 Standards Developed?
Following completion of the first phase of the One National
Program, EPA, NHTSA, and CARB conducted research and analysis
regarding the development of the MY2017-2025 standards.
A dialogue was established involving the government
agencies, automobile manufacturers, environmental groups, unions
and other interested stakeholders to obtain the views of these parties
on the new standards.
EPA and NHTSA issued several preliminary documents , which outlined
their plans to develop standards for MY2017-2025.
Q
A
23
24. OneNationalProgram101
What is a “Footprint”?
The footprint is a calculation
based on a vehicle’s track width
(vehicle width measured between
the tires) and the wheelbase
(vehicle length between the front
and rear tires).
In other words, the footprint is a measurement of a vehicle’s “shadow”
area, based on specified locations for measuring the width and length of
the vehicle.
Q
A
24
25. OneNationalProgram101
Do Cars and Trucks Have the Same Standards (If They Have the Same
Footprint)?Q
A Model Year 2025 CO2 and Fuel Economy Targets for Various Vehicle Types
Vehicle Type Example Model
Footprint (sq. ft.)
EPA CO2 Emissions Target
(g/mi)*
NHTSA Fuel Economy
Target (mpg)*
Example Passenger cars
Compact car 40 131 61.1
Midsize car 46 147 54.9
Full size car 53 170 48.0
Example Light-duty Trucks
Small SUV 44 170 47.5
Midsize crossover 49 188 43.4
Minivan 55 209 39.2
Large pickup truck 67 252 33.0
*Real World CO2 is typically 25 percent higher and real-world fuel economy is typically 20 percent lower than CO2 and CAFE values discussed here
Source: EPA Regulatory Announcement, August 2012, http://www.epa.gov/oms/climate/documents/420f12051.pdf
25
26. OneNationalProgram101
What Flexibilities Are Provided?
The flexibilities included in the regulations for MY2017-2025 include:
Credit Banking and Trading
Air Conditioning Improvement Credits
Off-Cycle Credits
Incentives for Electric Vehicles, Plug-In Hybrid Electric
Vehicles, Fuel Cell Vehicles and Compressed Natural Gas Vehicles
Incentives for Advanced Technologies; Including Hybridization for
Full-Size Pick-Up Trucks
Treatment of Compressed Natural Gas, Plug-In Hybrid Electric
Vehicles, and Flexible Fuel Vehicles
Mid-Term Review of the Standards
Provisions for Small Volume Manufactures
Q
A
26
27. OneNationalProgram101
What is Credit Banking and Trading?
Credit Banking and Trading provides manufacturers flexibility regarding the
timing of implementing new technologies. If a manufacturer implements
improved technology earlier than necessary to meet standards, it earns
credits that can be used to help meet future model year standards.
If a manufacturer defers implementing technologies, it can make up a
compliance shortfall by achieving higher levels of efficiency and emissions
performance in later years, and use the resulting credits to offset the
shortfall.
Q
A
27
28. OneNationalProgram101
CONTINUED:
What is Credit Banking and Trading?
Credits may be carried forward, or banked, for five years, or carried back
three years to cover a deficit in a previous year. Credit Banking and Trading
was also allowed under the MY2012-2016 standards.
The One National Program allows manufacturers to use credits in two
additional ways.
1. Manufacturers may transfer credits between their car and truck
fleets, to offset a shortfall in one of those fleets.
2. Manufacturers may trade credits with another manufacturer.
Q
A
28
29. OneNationalProgram101
CONTINUED:
What is Credit Banking and Trading?
Under the MY2017-2025 program, EPA is granting an additional
greenhouse gas (CO2) credit carry-forward provision, allowing credits
generated in MY2010-2016 to be used through MY2021.
From EPA Fact Sheet: “Together, these provisions help manufacturers
in planning and implementing the orderly phase-in of GHG-reducing
technology in their production, consistent with their typical redesign
schedules.”
Q
A
29
30. OneNationalProgram101
What Are Air Conditioning Improvement Credits?
Automobile manufacturers can generate additional credits by reducing
GHG emissions produced by vehicle air conditioning (A/C) systems. There
are three methods to reduce GHG emissions from A/C systems:
1. Change the A/C refrigerant. Using a different refrigerant with a
GHG potential reduces the environmental impact in the event of
an A/C system leak.
2. Improve the efficiency of the A/C system. If the A/C systems
requires less power to operate, then less GHG emissions result
from A/C usage.
3. Reduce the potential for A/C system leaks. Improved A/C system
components reduce the likelihood of A/C system leaks, thereby
reducing the potential for the A/C refrigerant, which is a GHG, to
be released into the air.
Q
A
30
31. OneNationalProgram101
What Are Off-Cycle Credits?
Some vehicle technologies provide greater emissions and energy
efficiency benefits in on-road driving than what is measured in the
laboratory test that is used for regulatory compliance.
The One National Program provides “off-cycle” credits to encourage
manufacturers to adopt these technologies. These credits add the
additional “real-world” benefits for these technologies to the laboratory
test results. Examples of these technologies include solar panels on
hybrid vehicles, engine start-stop, or active aerodynamics.
The standards include a pre-approved list of technologies that qualify
for off-cycle credits and would also allow manufacturers to apply for
off-cycle technology credits beyond those listed.
Q
A
31
32. OneNationalProgram101
What Incentives Are Provided for the Production of Electric, Plug-In Hybrid
Electric, Fuel Cell, and Compressed Natural Gas Vehicles?
To incentivize the introduction of these technologies, the program would
provides two incentives for these vehicles:
1. An incentive multiplier for all electric vehicles (EVs), plug-in hybrid electric
vehicles (PHEVs), fuel cell vehicles (FCVs), and compressed natural gas (CNG)
vehicles sold in MY2017-2021. This approach means that each of these
vehicles that is produced would count as more than a single vehicle, in
calculating fleet average compliance.
• EVs and FCVs would start with a multiplier value of 2.0 in MY2017,
phasing down to a value of 1.5 in MY2021.
• PHEVs and CNG vehicles would start at a multiplier value of 1.6 in
MY2017 and phase down to a value of 1.3 in MY2021.
• There is no multiplier for MY2022-2025.
Q
A
32
33. OneNationalProgram101
CONTINUED:
What Incentives Are Provided for the Production of Electric, Plug-In
Hybrid Electric, Fuel Cell, and Compressed Natural Gas Vehicles?
2. EPA set a value of zero (0) gram per mile tailpipe emissions for
EVs/PHEVs/FCVs through MY2021. This means that EPA will not assign
any “upstream” emissions to these vehicles, such as emissions
associated with the generation of electricity to charge the batteries of
electric vehicles.
EPA has placed a cap on the number of these vehicles that qualify for
the zero emission factor beginning in MY2022. Vehicles sold over the
cap limit would be assigned an upstream emission factor.
Q
A
33
34. OneNationalProgram101
What Special Incentives Are Provided for Full-Size Pick-Up Trucks?
There are three types of credits available for full-size pick-up trucks to
incentivize technology improvements in these vehicles:
1. “Mild” hybrid pickup trucks would be eligible for a per vehicle credit of 10
grams per mile during MY2017-2021 if the technology is used with at least
20 percent of a manufacturer’s MY2017 full-size pickup production and
ramping up to at least 80 percent in MY2021.
2. “Strong” hybrid pickup trucks would be eligible for a 20 gram per mile
credit during MY2017-2025 if the technology is used on at least 10 percent
of the manufacturer’s full size pickups.
3. Credits for the use of other advanced technologies in full size pick-up trucks
are available based on the amount by which they reduce GHG emissions.
The same truck can only receive credits based on one of these approaches
in a model year.
Q
A
34
35. OneNationalProgram101
How Are the Emissions from Dual Fuel Compressed Natural Gas, Plug-In
Hybrid Electric Vehicles and Flexible Fuel Vehicles Determined?
Plug-in hybrid electric vehicles (PHEVs)1, dual fuel compressed natural gas
(CNG)2 vehicles, and flexible fueled vehicles (FFVs)3 can all use two
different types of fuel.
In order to calculate the GHG emissions from these vehicles, an estimate of
the amount of each type of fuel that is typically used in the vehicle must be
made, since emission rates will in general vary when differing fuels are
used.
Q
A
1 Plug-in hybrid electric vehicles (PHEVs) use either electricity, gasoline or a combination of both at the same time.
2 Dual fuel compressed natural gas (CNG) vehicles can use either gasoline or CNG.
3 Flexible fueled vehicles (FFVs) can use either gasoline or a blend of high ethanol content with gasoline, known as E85. 35
36. OneNationalProgram101
CONTINUED:
How Are the Emissions from Dual Fuel Compressed Natural Gas, Plug-In
Hybrid Electric Vehicles and Flexible Fuel Vehicles Determined?
The following methods were determined for each vehicle type:
• The emission rates for PHEVs and dual fuel CNG vehicles will be based on
the assumption that the consumer will use the cheaper fuel the majority of
the time after having paid a premium to buy the vehicle. The fuel usage
estimates will be based on a Society of Automotive Engineers “utility
factor” methodology (based on vehicle range on the alternative fuel and
typical daily travel mileage) to determine the assumed percentage of
operation on gasoline and percentage of operation on the alternative fuel.
• FFV GHG emissions will be calculated based on the use of only gasoline
fuel, due to the low volume of ethanol fuel (E85) that is sold in the U.S.
However, EPA will allow a manufacturer to use an assumption of a higher
use rate of ethanol if a manufacturer demonstrates that E85 is actually
being used in its vehicles at the higher rate.
Q
A
36
37. OneNationalProgram101
What Is the Mid-Term Review of the Standards?
Automobile manufacturers need adequate lead time to develop vehicles
that meet the required standards, but setting standards for model years
10-13 years in the future creates uncertainty about the future vehicle
market, as well as the cost and performance of advanced technologies
that were projected to be developed for those years.
As a result, EPA and NHTSA will conduct a review of the standards for
MY2022-2025, issuing a decision no later than April 1, 2018. In this “mid-
term review,” EPA and NHTSA will evaluate the newest data and the state
of the vehicle market. The findings from the mid-term review will be
provided to the public for their input prior to an agency decision on
whether to amend or maintain the MY2022-2025 standards.
Q
A
37
38. OneNationalProgram101
CONTINUED:
What Is the Mid-Term Review of the Standards?
Under law, NHTSA cannot set standards for more than five years at a
time. Therefore it initially finalized standards only for MY2017-2021.
In a separate proceeding that will coincide with the mid-term
review, it will promulgate CAFE standards for MY2022-2025.
Q
A
38
39. OneNationalProgram101
Are the EPA GHG and NHTSA CAFE Standards Identical In Scope and
Stringency?
EPA and NHTSA have generally harmonized their GHG and CAFE programs
in order to simplify manufacturers’ compliance obligations.
However, although the purposes of the two programs are closely aligned,
there are some policy differences and some differences in the legal
authority for the two agencies.
These differences have led to differences in the scope and stringency of
the two sets of standards. For example, EPA has addressed some
additional climate-related concerns with its standards, beyond the
primary focus on CO2 emissions.
Q
A
39
40. OneNationalProgram101
CONTINUED:
Are the EPA GHG and NHTSA CAFE Standards Identical In Scope and
Stringency?
EPA has adopted requirements regarding the emissions of the GHGs
methane and nitrous oxide and the leakage of air conditioning system
refrigerants. There are also detailed legal restrictions on CAFE standard-
setting that were not applied in developing EPA’s standards.
For instance, the standards for MY2025 are:
• EPA: 163 g/mi GHG, or an equivalent of 54.5 mpg
• NHTSA: 49.6 mpg
Q
A
40
41. OneNationalProgram101
Environmental Protection Agency (EPA)
• EPA Fuel Economy Fact Sheet
• Fuel Economy
• Fuel Economy Guide
• Fuel Economy Label
• Greenhouse Gases/Corporate Average Fuel Economy National Program
• Gases Standards Compliance Information for Light-Duty Vehicles
National Highway Traffic Safety Administration (NHTSA)
• Corporate Average Fuel Economy (CAFE)
California Air Resources Board (CARB)
• CARB Main Page
• Regulatory - Advanced Clean Cars
References
41